MEMORANDUM OPINION
MORRIS, Chief Judge.
I. INTRODUCTION.
This is a civil tax controversy in which plaintiff seeks to recover $2,231.06 in social security and withholding taxes collected for certain quarters during the years 1964 through 1967, 1971 and 1972, which the taxpayer claims were erroneously assessed and collected. The defendant counterclaims for an additional $82,482.23 for employment tax deficiencies, penalties and interest allegedly...
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